- 62 - charge of the offices there; (iii) that Chemical Traders and Polymer were legitimate businesses that bought and sold products under their own names; (iv) that secrecy was not the reason he wrote checks to cash, and cashier's checks to withdraw funds from the Polymer and Chemical Traders accounts; (v) that Levenson suggested the Polymer scheme; and (vi) that he never stopped at Levenson's house to have Levenson sign blank checks. Petitioner testified that petitioner Ruth Levitt was an original subscriber of Welev stock. However, the corporate minutes show that she was not. Finally, petitioner testified that he had nothing to do with preparing Ruth Levitt's income tax return for 1986. However, Ruth Levitt testified that he always handled their tax returns and that she never participated in preparing income tax returns. 4. Petitioners' Contentions Petitioners contend that petitioner's concealment in 1986 of the Welev transaction is not relevant to proving that petitioner committed fraud for the tax years in issue because it occurred after the years in issue. We do not consider petitioner's acts of concealment in 1986 in deciding the fraud issue. However, we consider the fact that petitioner used Resyn to pay for Welev during the years in issue but did not report the amounts that Resyn paid. Petitioners contend that the fact that Philbin never saw petitioner involved in Resyn's bookkeeping or instructing anyonePage: Previous 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 Next
Last modified: May 25, 2011